PUBLIC DISCLOSURE


September 30, 2021


COMMUNITY REINVESTMENT ACT PERFORMANCE EVALUATION

International Finance Bank
Certificate Number: 24823

777 SW 37th Avenue, Suite 700
Miami, Florida 33135


Federal Deposit Insurance Corporation
Division of Depositor and Consumer Protection
Atlanta Regional Office

10 10th Street NE, Suite 800
Atlanta, Georgia 30309-3849

This document is an evaluation of this institution's record of meeting the credit needs of its entire community, including low- and moderate-income neighborhoods, consistent with safe and sound operation of the institution. This evaluation is not, nor should it bc construed as, an assessment of the financial condition of this institution. The rating assigned to this institution does not represent an analysis, conclusion, or opinion of the federal financial supervisory agency concerning the safety and soundness of this financial institution.

TABLE OF CONTENTS

INSTITUTION RATING	1
DESCRIPTION OF INSTITUTION	2
DESCRIPTION OF ASSESSMENT AREAS	3
SCOPE OF EVALUATION	3
CONCLUSIONS ON PERFORMANCE CRITERIA	5
DISCRIMINATORY OR OTHER ILLEGAL CREDIT PRACTICES REVIEW	9
STATE OF FLORIDA	10
DESCRIPTION OF INSTITUTION’S OPERATIONS IN FLORIDA	10
SCOPE OF EVALUATION - FLORIDA	13
CONCLUSIONS ON PERFORMANCE CRITERIA IN FLORIDA	13
STATE OF NEW YORK	19
DESCRIPTION OF INSTITUTION'S OPERATIONS IN NEW YORK	19
SCOPE OF EVALUATION — NEW YORK	22
CONCLUSIONS ON PERFORMANCE CRITERIA IN NEW YORK	22
APPENDICES	24
INTERMEDIATE SMALL BANK PERFORMANCE CRITERIA	24
SUMMARY OF RATINGS FOR RATED AREAS	25
GLOSSARY	26

Institution Rating

INSTITUTION'S CRA RATING: This institution is rated Satisfactory.

• The Lending Test is rated Satisfactory.
• The Community Development Test is rated Satisfactory.

The loan-to-deposit ratio is reasonable given the institution's size, financial condition, and assessment area credit needs. A majority of the institution's loans were originated within the assessment areas.

Description of Institution

International Finance Bank (IFB) is a state-chartered commercial bank headquartered in Miami, Florida. IFB currently operates two full-service offices, including its main office in Miami, Florida and an office in New York City, New York. IFB's assets totaled $926.9 million, as of June 30, 2021.

Loan Portfolio Distribution as of 6/30/2021

Loan Category	$(000s)	%
Construction, Land Development	29,175	4.1
Secured by Farmland	0	0.0
Secured by 1-4 Family Residential	158,782	22.2
Secured by Multifamily (5+)	57,947	8.1
Secured by Nonfarm Nonresidential	197,585	27.7
Total Real Estate Loans	443,489	62.1
Commercial and Industrial	241,385	34.4
Consumer Loans	20,258	2.8
Other Loans	6,396	0.9
Less: Unearned Income	(1,782)	(0.2)
Total Loans	713,746	100.0

Source: Report of Condition and Income.

Scope of Evaluation

This evaluation covers the period from the previous evaluation dated September 27, 2018, to the current evaluation dated September 30, 2021. Examiners used Interagency Intermediate Small Institution Examination Procedures to evaluate IFB's CRA performance. As shown in the assessment area breakdown, the Miami-Miami Beach-Kendall, FL MD assessment area comprises a significant majority of the loans reviewed (99.4 percent) and deposits (82.0 percent). Consequently, examiners gave considerably more weight to the bank's overall performance in the State of Florida.

Conclusions on Performance Criteria

LENDING TEST

Overall, IFB demonstrated satisfactory performance under the Lending Test. The bank's net loan-to-deposit (NLTD) ratio is reasonable... averaging 88.5 percent for the previous 12 quarters.

Lending Inside and Outside of the Assessment Areas

Loan Category	Inside				Outside				Total (000s)
	#	%	$(000s)	%	#	%	$(000s)	%
Home Mortgage
2019	49	94.2	53,702	96.3	3	5.8	2,048	3.7	55,750
2020	38	63.3	36,600	54.4	22	36.7	30,618	45.6	67,218
Small Business
2019	31	68.9	11,844	61.4	14	31.1	7,439	38.5	19,283
2020	57	90.5	7,419	94.9	6	9.5	398	5.1	7,817
Totals	175	79.5	109,565	73.0	45	20.5	40,503	27.0	150,068

Source: Bank Data.

COMMUNITY DEVELOPMENT TEST

The institution's community development performance demonstrates adequate responsiveness... IFB originated or purchased 38 community development loans totaling $40.2 million.

Community Development Activities Table

Assessment Area	Loans #	Loans $(000s)	Investments #	Investments $(000s)	Services #
Miami-Miami Beach-Kendall, FL	18	34,655	25	3,181	22
New York-Jersey City, NY-NJ	19	2,645	9	1,100	1
Statewide (FL)	1	2,918	2	122	0
Totals	38	40,218	36	4,403	23

Source: Bank Records.

Discriminatory or Other Illegal Credit Practices Review

The bank's compliance with the laws relating to discrimination and other illegal credit practices was reviewed, including the Fair Housing Act and the Equal Credit Opportunity Act. Examiners did not identify any discriminatory or other illegal credit practices.

State of Florida Assessment

CRA RATING FOR FLORIDA: SATISFACTORY.

The assessment area includes all 519 census tracts in Miami-Dade County.

Demographic Info (Florida Assessment Area)

Characteristics	#	Low %	Mod %	Mid %	Upp %
Census Tracts	519	5.8	27.7	28.9	34.1
Population	2,639,042	5.5	29.7	30.9	33.2
Housing Units	998,833	5.3	27.5	29.3	37.2
Businesses	533,780	3.1	20.8	25.9	47.8

Source: 2015 ACS Census and 2020 D&B Data.

Geographic Distribution (Florida): The geographic distribution of home mortgage and small business loans reflects reasonable dispersion throughout the assessment area. In 2019, the bank's home mortgage lending in low-income census tracts was consistent with aggregate data. In 2020, lending was lower but opportunities were limited.

Geographic Distribution of Home Mortgage Loans (Florida)

Tract Income Level	% of Owner-Occupied	Aggregate Performance %	Bank 2019 #	Bank 2019 %	Bank 2020 #	Bank 2020 %
Low	2.0	1.8	1	2.0	0	0.0
Moderate	21.4	18.6	7	14.3	6	16.2
Middle	31.9	31.9	4	8.2	3	8.1
Upper	44.4	47.0	35	71.4	22	59.5

Borrower Profile (Florida): The distribution of borrowers reflects poor penetration among individuals of different income levels. The bank originated no loans to low- or moderate-income borrowers in 2019 or 2020.

State of New York Assessment

CRA RATING FOR NEW YORK: NEEDS TO IMPROVE.

The Lending Test is rated: Needs to Improve.
The Community Development Test is rated: Satisfactory.

The assessment area includes all 2,057 census tracts in Bronx, Kings, New York, and Queens counties.

Demographic Info (New York Assessment Area)

Characteristics	#	Low %	Mod %	Mid %	Upp %
Census Tracts	2,057	13.9	27.3	29.8	25.9
Population	7,954,262	17.6	30.3	26.2	25.6
Businesses	794,884	8.9	21.3	20.5	46.4

Source: 2015 ACS Census and 2020 D&B Data.

Conclusions (New York): Overall, examiners could not form reasonable conclusions regarding the bank's geographic distribution of loans and distribution of borrowers because of the low volume of home mortgage and small business loans originated in this assessment area. The bank originated no home mortgage loans in 2019 and only one in 2020.

Appendices

Intermediate Small Bank Performance Criteria:

• Lending Test: Evaluates loan-to-deposit ratio, percentage of loans in assessment area, geographic distribution, and borrower profile.
• Community Development Test: Evaluates number and amount of community development loans, qualified investments, and services.

Summary of Ratings

Rated Area	Lending Test	Community Development Test	Rating
Florida	Satisfactory	Satisfactory	Satisfactory
New York	Needs to Improve	Satisfactory	Needs to Improve

Aggregate Lending: The number of loans originated and purchased by all reporting lenders in specified income categories as a percentage of the aggregate number of loans originated and purchased by all reporting lenders in the metropolitan area/assessment area.

American Community Survey (ACS): A nationwide United States Census survey that produces demographic, social, housing, and economic estimates.

Area Median Income: The median family income for the MSA, if a person or geography is located in an MSA.

Assessment Area: A geographic area delineated by the bank under the requirements of the Community Reinvestment Act.

Census Tract: A small, relatively permanent statistical subdivision of a county or equivalent entity... generally have a population size between 1,200 and 8,000 people.

Community Development: Activities that support affordable housing, target community services toward low- and moderate-income individuals, promote economic development by financing small businesses, or revitalize/stabilize low- and moderate-income geographies.

Community Development Financial Institutions (CDFIs): Private intermediaries (either for profit or nonprofit) with community development as their primary mission.

Consumer Loan(s): A loan(s) to one or more individuals for household, family, or other personal expenditures.

Family: Includes a householder and one or more other persons living in the same household who are related to the householder by birth, marriage, or adoption.

Geography: A census tract delineated by the United States Bureau of the Census in the most recent decennial census.

Home Mortgage Disclosure Act (HMDA): The statute that requires certain mortgage lenders... to file annual summary reports of their mortgage lending activity.

Low-Income: Individual income that is less than 50 percent of the area median income.

Market Share: The number of loans originated and purchased by the institution as a percentage of the aggregate number of loans originated and purchased by all reporting lenders in the metropolitan area/assessment area.

Middle-Income: Individual income that is at least 80 percent and less than 120 percent of the area median income.

Moderate-Income: Individual income that is at least 50 percent and less than 80 percent of the area median income.

Small Business Loan: Loans included in “loans to small businesses”... having original amounts of $1 million or less.

Upper-Income: Individual income that is 120 percent or more of the area median income.